This comment examines the cae of Employment Division, Department of Human Resources of Oregon v. Smith, and Congress' response to that decision in the Religious Freedom Restoration Act (RFRA). The Comment further examines whether the Supreme Court's 1879 Decision in Reynolds v. United States, which upheld laws against polygamy in the Utah Territory, would continue to be viable in light of the RFRA and Free Excercise Clause cases that have been decided since.